- 2 - Respondent determined a deficiency in petitioners’ Federal income tax, an accuracy-related penalty, and an addition to tax for 1997 as follows: Penalty Addition to tax Year Deficiency Sec. 6662 Sec. 6651(a)(1) 1997 $7,889 $1,577.80 $441 After concessions by petitioners,2 the issues for decision are as follows: (1) Whether for 1997, the taxable year in issue, petitioners are entitled to a deduction under section 165(c)(2) for a loss attributable to (a) the unauthorized removal of furnishings and fixtures from an apartment building in 1996 and (b) the foreclosure on such building in 1996. We hold that they are not. (2) Whether petitioners are liable for the accuracy-related penalty under section 6662(a) for negligence or intentional disregard of rules or regulations. We hold that they are to the extent provided herein. 2 In the petition, petitioners disputed the entire deficiency determined by respondent in the notice of deficiency. However, petitioners did not assign any error or allege any facts with respect to respondent’s determinations regarding: (1) The receipt of unreported nonemployee compensation in the amount of $3,525; (2) the imposition of self-employment tax on such nonemployee compensation; and (3) the disallowance of itemized deductions for charitable contributions and unreimbursed employee expenses. Moreover, at trial, petitioners did not dispute any of these adjustments. Accordingly, we regard petitioners as having conceded these matters.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011